Personal Data Protection Policy
Last updated: February 2025
The purpose of this Personal Data Protection Policy (hereinafter the “Privacy Policy”) is to inform you, as user of the INSIDE LVMH Platform (hereinafter “You”) about how Moët Hennessy SAS, a company located at 24-32 rue Jean Goujon, 75008 Paris, France, registered with the Paris Trade and Companies register under number 338 228 414, telephone number 01 44 13 22 22, (hereinafter “LVMH” or “We” or “Us”) processes the personal data (hereinafter the “Personal Data” or “Data”) that You provide when You register through a Platform entitled “INSIDE LVMH” available at www.insidelvmh.com (hereinafter the “Platform”) and further use the Platform to participate to the INSIDE LVMH certificate (hereinafter the “INSIDE Certificate” or the “Certificate”) and about your rights in this respect.
LVMH places the highest priority and take the utmost care to protect your personal data.
Note: The present Privacy Policy may be modified, in particular if a new processing of Personal Data is carried out. Please check this page regularly to ensure that You agree with any changes. You will be notified of any significant changes, either through a special note on our Platform or through a personal notification.
1. What is a “personal data”?
Personal Data refers to any information or pieces of information that could identify You either
· directly (e.g. your name, surname, email, home address, etc.)
· or indirectly (e.g. through pseudonymized data, such as a unique ID number, etc.).
2. Data controller and Data Protection Officer
2.1. Who is the Data Controller?
The Data Controller is the entity that determines the means and purposes of Personal Data Processing and who is responsible to the Employees for complying with the applicable personal data protection legislation.
As regards the management of your Data for your participation to the Certificate, the Data Controller is Moët Hennessy SAS, a company located at 24-32 rue Jean Goujon, 75008 Paris, France, registered with the Paris Trade and Companies register under number 338 228 414.
2.2. Who is the LVMH Data Protection Officer?
LVMH has appointed a Data Protection Officer (hereinafter “DPO”). For the purpose of your participation to the INSIDE Certificate, LVMH’s DPO will be your designated contact person that may be reached:
· by email at the following address: dpo.holding@lvmh.com.
· by mail at the following address: LVMH Data Protection Officer, 24-32 rue Jean Goujon, 75008 Paris, France.
3. What Processing is done on your Personal Data?
3.1. What kind of Personal Data does LVMH process?
The list of Personal Data processed in each of the purposes described above is in the table attached in Appendix 1.
3.2. How are your Personal Data collected?
We collect your Personal Data
· directly from You when You (i) register through the Platform, (ii) further participate to the INSIDE Certificate, (iii) fill in the questionnaire to customize your INSIDE LVMH Certificate and (iii) ask us questions through the chatbot on the Platform;
· indirectly when We take pictures of You during the events organized as part of the INSIDE Certificate with your express prior consent;
· automatically when You access or use the Platform (technical details, IP address, browsing information, connection via SSO for internal employees, etc.).
3.3. What are the purposes and legal grounds for processing your Personal Data?
In accordance with current personal data protection regulations, We only process your Personal Data when We have a legal basis to do so.
We process your Personal Data based for the following purposes:
1. Manage your registration on the Platform based on the performance of the Terms and Conditions of Use of the Platform concluded between us.
2. Manage your registration and participation in the INSIDE Certificate, including personalizing it, and the issuance of the certificate upon successful completion, based on the performance of the Terms and Conditions of Use of the Platform concluded between us.
3. Manage your data subjects’ rights according to article 4 of this Privacy Policy based on our legitimate interest.
4. Communicate your email address to LVMH and its Maisons HR to contact You for recruitment purpose and coaching purpose based on your consent. Only if you are not a LVMH Maison’s employee and you get the INSIDE LVMH Certificate.
5. Communicate your success and score to the final exam of the INSIDE LVMH Certificate to your university based on your consent.
7. Communicate your success to your Maisons HR departments based on your consent if you get the INSIDE LVMH Certificate. Only if you are a LVMH Maison’s employee.
8. Communicate with you based on your consent (e.g., if you ask us questions via the chatbot).
9. Send you our newsletter, based on your consent.
10. To defend our rights or to comply to laws when required.
If You decide to apply to one of LVMH and/or Maison job offers and/or to the INSIDE LVMH Certificate Talent Pool, your Personal Data will be processed to take steps at your request prior to entering into a possible contract, in accordance with LVMH and/or each Maison privacy policy.
3.4. Who has access to your Personal Data?
The detailed list of persons who have access to your Personal Data is in the table attached in Appendix 1.
3.4.1. Accessibility within LVMH
Your Data will be accessible to the representatives of LVMH in charge of the Platform and the Certificate.
When You choose to participate to the INSIDE Certificate:
· your questionnaire’s answers are only accessible to the authorized persons in charge of managing this Platform and the Certificate.
· your email address will be accessible to LVMH Group’s HR departments, if You give your consent to be contacted for recruitment purpose.
3.4.2. Accessibility by third parties
Certain third parties may also have access to your Data, specifically:
· our data processors and providers involved for technical and logistical reasons (Platform hosting and maintenance, chatbot, sending newsletters or other communications, providing the Certificate and any other content made available on the Platform);
· for students, any university that requests or proposes a student to enroll in the Certificate;
· for employees of the LVMH Group, any Maison that proposes employees to enroll in the Certificate;
· any authority, court or other third party when disclosure is required by law, regulations or a judicial decision, or if such disclosure is necessary to protect and defend our rights.
3.5. How long will your Personal Data be kept
The detailed list of how long your Personal Data will be kept by LVMH is in the table attached in Appendix 1.
In general, unless stated otherwise in Appendix 1, your Personal Data will be stored and processed by LVMH throughout the duration of the Certificate and will then be archived for the duration of the applicable term (2 years, as applicable).
In relation with your INSIDE LVMH certificate obtained, if so: the certificate will be deleted with the anonymization of your account data.
3.6. Transfers of Personal Data outside the EEA
Your Data will be accessible to the personnel of the LVMH Group who may be located outside of the European Union (EU) in countries where personal data protection laws differ from those that apply in the EU.
Likewise, We rely on certain service providers, which are located abroad or which themselves rely on processors located abroad, including outside of the EU in countries where personal data protection laws differ from those that apply in the EU.
In addition, based on your consent, we may communicate your success and score to the final exam of the INSIDE LVMH certificate to your university, which may be located outside the EU.
Any transfer of your Data outside of the EU takes place with appropriate contractual safeguards in place that comply with applicable personal data protection regulations.
Upon request, We can provide You with a list of countries where We store or process your Data, or through which your Data may occasionally transit, inform You of the safeguards used on a case-by-case basis and, where applicable, provide You with a copy of the contractual safeguards.
4. What are your rights in relation to the protection of your Personal Data?
4.1. Access, rectification and portability
In accordance with current regulations, You have the right to access your Data. You may also request correction of Your Personal Data should they be inaccurate. Depending on the purpose of processing, You also have the right to have incomplete Personal Data completed.
To respond to your request, We may ask You to provide Us with a proof of your identity. We may also need to ask You for additional information or supporting documents. We will make every effort to respond to your request as soon as possible.
You may, to the extent provided for by law, exercise your right to Data portability which allows You to retrieve, in an interoperable format, the Personal Data that You provided to Us.
4.2. How to exercise your right to erasure of your Data and to limit the processing of your Data?
You can ask for the erasure of your Data in the following occasion:
· You believe that our processing of your Personal Data is no longer necessary for your participation to the INSIDE LVMH Certificate or your use of the Platform.
· You believe that the processing is unlawful.
· You withdraw your consent on which the processing is based and where there is no other legal ground for the processing.
· You believe that the Personal Data have to be erased for compliance with a legal obligation in Union or Member State law to which LVMH (the data controller) is subject.
You may request restriction of the processing:
· instead of erasure of the personal data, if You believe that the processing is unlawful,
· if You contest the accuracy of the Personal Data We process about You.
· if We no longer need the Personal Data for the purposes of the processing, but You require those Personal Data for the establishment, exercise or defence of legal claims.
You also have the right to be informed by Us before the restriction of processing is lifted when You have obtained restriction of processing.
Please note that despite the exercise of your right to erasure or processing limitation, We will store some of your Personal Data when the law requires Us to do so or to exercise or defend our rights.
4.3. Right to establish instructions for the management of your Personal Data after your death
For France in accordance with Article 63 of Law No. 2016-1321 of 7 October 2016 on a digital Republic and when mandatory local provisions so provide, You may determine how You want Us to handle your Personal Data upon your death.
4.4. Procedure to exercise your rights in relation to your Data
You may exercise your rights (right to access, rectification and/or erasure, etc.) by accessing your account (via the “Help” button).
You may also contact our DPO at dpo.holding@lvmh.com or by mail at LVMH Data Protection Officer, 24-32 rue Jean Goujon, 75008 Paris, France.
To respond to your request, you may be asked, if necessary, to provide a proof of your identity. You may also be asked for additional information or supporting documents.
5. How is the security of your Personal Data ensured?
LVMH uses technical and organizational measures that comply with French and EU legal and regulatory requirements, to keep your Data secure and confidential.
Under written agreements, LVMH requires its service providers and processors to provide safeguards and implement sufficient security measures to protect the Personal Data they have agreed to process, in accordance with applicable requirements under personal data protection laws.
However, LVMH does not control all risks related to the operation of the Internet and draws your attention to the inherent risks of using any website.
6. Cookies
When You visit the Platform, cookies, which are small files of letters and numbers, are downloaded on to your computer.
How do we use cookies?
We only use:
· with your consent, analytics cookies to create statistics about the use of the Platform. These statistics do not process any personal data.
How can You manage cookies?
Please use our cookie management tool in the platform (cookies banner and privacy preference settings menu).
7. Third party websites
There may be links to third-party websites that We do not control, and which are governed by their own confidentiality and personal data protection policies.
This Privacy Policy does not apply to third-party websites.
Please review the confidentiality and personal data protection policies of the third-party websites that You visit to understand how they process your Data. LVMH shall not be liable for any use of your Data by any third parties.
8. How can You contact Us if You have queries or complaints?
For any questions concerning this Privacy Policy or for any queries or complaints regarding your Personal Data, please contact our DPO at dpo.holding@lvmh.com or at LVMH Data Protection Officer, 24-32 rue Jean Goujon, 75008 Paris, France.
If You have a complaint about the way We process your Data, You also have the right to contact the Commission Nationale de l’Informatique et des Libertés (French data protection authority) (CNIL), 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07, Tel: 01 53 73 22 22, www.cnil.fr.
